ML20310A223
| ML20310A223 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/19/2020 |
| From: | Samson Lee NRC/NRR/DORL/LPL1 |
| To: | Wolf Creek |
| Lee S-NRR/DORL 301-415-3168 | |
| References | |
| EPID: L-2020-LRM-0104 | |
| Download: ML20310A223 (15) | |
Text
License Amendment Request for On-Shift ERO Staffing Reduction Pre-Submittal Meeting for:
Wolf Creek Nuclear Operating Company (WCNOC),
Wolf Creek Generating Station (WCGS) 11/19/2020
- WCNOC Participants
Agenda
- Pre-Submittal Meeting Purpose
- Emergency Plan Licensing Basis
- Proposed Emergency Plan Changes
- LAR Format
- LAR Schedule
- Conclusions
- Questions?
Pre-Submittal Meeting Purpose
- Establish communication with NRC staff in order to identify:
- Applicable review criteria/standards
- Level of detail and supporting analysis needed
- Identification and applicability of precedents
- Feasibility of desired schedule
- Outline proposed Emergency Plan changes
- Discuss LAR Development process and preliminary content
Emergency Plan Licensing Basis
- Last NRC approved Emergency Plan is procedure AP 06-002, Revision 20 (License Amendment 220, dated April 1, 2019)
- Current Emergency Plan is procedure AP 06-002, Revision 21
- License Amendment 220 included an analysis of NUREG-0654, R/2, Table B-1 functions as implemented in the Emergency Plan
Proposed Emergency Plan Changes
- Reduce on-shift Emergency Response Organization (ERO) staffing by two (2) Nuclear Station Operators (NSO) and one (1) RP Technician by:
- Utilizing the Work Control Senior Reactor Operator (WCSRO) as the Emergency Notification System (ENS)
Communicator and Off-site Communicator (OSC)
- Reassigning Site Watch mitigation functions to other NSOs
- Assigning Dose Assessment and Control Room Radiation Protection duties to one qualified Dose Assessor.
Position 1: WCSRO as ENS/OSC Communicator
- WCSRO is now the dedicated Shift Technical Advisor (STA) separate from the other Shift Manager (SM) /
Senior Reactor Operator (SRO) positions
- Eliminates dedicated STA position by allowing the STA functions to be combined with one or more of the required SM/SRO positions (Option 1 of GL 86-04)
- WCSRO would now be used as ENS/OSC communicator
- WCSRO will not have collateral duties while assigned ENS/OSC Communicator duties
Position 1: WCSRO as ENS/OSC Communicator
- WCNOC Tech Specs have already adopted the enabling STS wording to get rid of the separate title Shift Technical Advisor
- Change does not invalidate any conclusions reached in NRCs Safety Evaluation Report (SER) for WCNOC Amendment 220
- Removes one NSO currently filling the ENS/OSC communicator position
Position 2: Reassign Site Watch Mitigation Functions
- Site Watch NSO has no assigned emergency planning, firefighting, or collateral duties
- Site Watch is only required for Mitigation
- Previous addition of two Fire Brigade Members (FBM) as NSOs can perform the Site Watch Mitigation functions
- Optimization of these mitigation functions would not create a competing collateral duty or impact any emergency planning functions
- Removes one NSO emergency planning position
Position 3: Dose Assessor/Rad Protection Position
- Chem Tech currently performs Dose Assessment in the Control Room
- Dose Assessor will be responsible for the Major Task of Personnel Monitoring in the Control Room
- Dose Assessor will be task qualified for the following basic RP duties:
- Perform on-site radiation surveys;
- Perform on-site contamination surveys;
- Set up a step-off pad for access to the control room.
- This position will be titled On-Shift Dose Assessor
- Reduces on-shift staffing by one RP Tech
LAR Format
- Enclosures/Attachments include:
- Technical Justification
- Functional analysis of Table B-1 Major Tasks
- Summary table of Emergency Plan changes
- Marked up copy of the Emergency Plan
- Clean copy of the Emergency Plan
- Table B-1 Comparative Chart
- Commitments
Regulatory Guidance
- RG 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors
- NUREG-0654/FEMA-REP-1, Rev. 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants
- NSIR/DPR-ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants
- RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation
- NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities
- NEI 12-01, Guideline for Assessing Beyond Design Basis Accidents Response Staffing and Communications Capabilities
LAR Schedule
- Submittal of LAR by end of first quarter 2021
- Request approval by end of first quarter 2022
- Propose a 180-day implementation period
Conclusions
- Proposed staffing continues to minimize impact of radiological emergencies and provides protection of public health and safety
- Supported by technical justification and functional analysis
- Revised Emergency Plan continues to meet
§50.54(q)(2), §50 Appendix E, and the planning standards of §50.47(b)
- Draft on-shift staffing analysis completed to verify that remaining ERO positions were not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the Emergency Plan
Questions